February 1, 2007

Via U.S. Mail and Facsimile

K. Paul Singh
Chief Executive Officer
Primus Telecommunications, Incorporated
7901 Jones Branch Road
Suite 900
McLean, VA

RE:		Primus Telecommunications Group, Incorporated
		Form 10-K for the fiscal year ended December 31, 2005
		File No. 0-29092

Dear Mr. Singh:

      We have limited our review of your Form 10-K for the fiscal
year ended December 31, 2005, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism.  Our review with respect to this issue does not
preclude further review by the Assistant Director group with
respect
to other issues.  At this juncture, we are asking you to provide
us
with supplemental information, so that we may better understand
your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -
1. We note that you list on your website rates for your Primus
Prepaid Phone Card including rates for Cuba, Iran, North Korea,
Sudan
and Syria.  These countries are identified as state sponsors of
terrorism by the U.S. State Department and are subject to U.S.
economic sanctions and controls. Please describe your current,
past
and anticipated operations in and contacts with these countries,
whether directly or through subsidiaries or affiliated entities or
other indirect arrangements, and discuss their materiality to you
in
light of the countries` status as state sponsors of terrorism.
Please also discuss whether the contacts and operations,
individually
or in the aggregate, constitute a material investment risk to your
security holders.
2. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
revenues, assets and liabilities associated with Cuba, Iran, North
Korea, Sudan and Syria.  Please also address materiality in terms
of
qualitative factors that a reasonable investor would deem
important
in making an investment decision, including the potential impact
of
corporate activities upon a company`s reputation and share value.
We note, for example, that Arizona and Louisiana have adopted
legislation that requires their state retirement systems to
prepare
reports regarding state pension fund assets invested in, and/or
permits divestment of state pension fund assets from, companies
that
do business with U.S.-designated state sponsors of terrorism.
Pennsylvania`s General Assembly has passed a resolution mandating
assessment and reporting of state pension fund assets invested in
companies that do business with certain U.S.-designated state
sponsors of terrorism.  Florida requires issuers to disclose in
their
prospectuses any business contacts with Cuba or persons located in
Cuba.  Connecticut, Illinois, Maine, New Jersey and Oregon have
adopted legislation requiring reporting of interests in, or
divestment from, companies that do business with Sudan, and
similar
legislation has been proposed by several other states. Finally,
Harvard University, Yale University, Stanford University, and
other
educational institutions have adopted policies prohibiting
investment
in, and/or requiring divestment from, companies that do business
with
Sudan.  Your materiality analysis should address the potential
impact
of the investor sentiment evidenced by such actions directed
toward
companies that have operations associated with Cuba, Iran, North
Korea, Sudan and Syria.







Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.
								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Larry Spirgel
		Division of Corporation Finance
K. Paul Singh
Primus Telecommunications, Incorporated
February 1, 2007
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE